Paradoxical EU agricultural policies on genetically engineered crops

TRPLSC-1050; No. of Pages 13
Review
Feature Review
Paradoxical EU agricultural policies on
genetically engineered crops
Gemma Masip1, Maite Sabalza1, Eduard Pérez-Massot1, Raviraj Banakar1, David
Cebrian1, Richard M. Twyman2, Teresa Capell1, Ramon Albajes1, and Paul Christou1,3
1
Department of Plant Production and Forestry Science, ETSEA, University of Lleida-Agrotecnio Center, Av. Alcalde Rovira Roure,
191, 25198 Lleida, Spain
2
TRM Ltd, PO Box 93, York, YO43 3WE, UK
3
Institució Catalana de Recerca i Estudis Avançats, Passeig Lluı́s Companys 23, 08010 Barcelona, Spain
European Union (EU) agricultural policy has been developed in the pursuit of laudable goals such as a competitive
economy and regulatory harmony across the union. However, what has emerged is a fragmented, contradictory,
and unworkable legislative framework that threatens
economic disaster. In this review, we present case studies
highlighting differences in the regulations applied to
foods grown in EU countries and identical imported products, which show that the EU is undermining its own
competitiveness in the agricultural sector, damaging
both the EU and its humanitarian activities in the developing world. We recommend the adoption of rational,
science-based principles for the harmonization of agricultural policies to prevent economic decline and lower
standards of living across the continent.
Importance of agriculture in the EU
Agriculture is one of the most important pillars of social
and economic development in the EU, and Europe remains
one of the world’s largest traders in agricultural products
(Figure 1) (http://ec.europa.eu/agriculture/publi/map/01_
12_en.pdf). However, a substantial genetic gain in yield
potential and stress resistance is required to ensure that
sustainable agricultural practices can be developed to meet
the demands of a growing population in Europe and in the
many agriculture-dependent developing countries (http://
www.fao.org/fileadmin/templates/wsfs/docs/expert_paper/
How_to_Feed_the_World_in_2050.pdf) [1].
EU agricultural policy is proposed by the European
Commission, approved by agriculture ministers in EU
member states, and ratified by the European Council
and Parliament. The stated objectives are to support
farm incomes, encourage the production of high-quality
goods led by domestic and export market demands,
promote environmentally sustainable practices, and increase the competitiveness of European agriculture
(http://ec.europa.eu/agriculture/cap-overview/2012_en.
Corresponding author: Christou, P. (christou@pvcf.udl.es).
Keywords: genetically engineered crops; EU agricultural policies; CAP; pesticides;
food security.
1360-1385/$ – see front matter
ß 2013 Elsevier Ltd. All rights reserved. http://dx.doi.org/10.1016/j.tplants.2013.
03.004
pdf). However, the common agricultural policy (CAP) of the
EU has provoked intense criticism because it reduces
competitiveness, productivity, and sustainability, and ultimately invites economic and social instability (http://www.
agriregionieuropa.univpm.it/materiale/2011/Erjavec_
OptionsForTheCAP_16_2_2011.pdf). Although they aim to
promote environmentally sustainable agricultural practices, nutritious food, and inexpensive medicines, EU policies hamper the development of key technologies to achieve
those objectives.
There are three major paradoxes in current EU agricultural policy that not only affect agriculture directly but also
have knock-on effects on the environment, on human
health, on the wider economy, and on food security in
developing countries. First, the Lisbon Strategy aims to
create an EU knowledge-based bioeconomy (KBBE) and
recognizes the potential of genetically engineered (GE)
crops to deliver it [2], but EU policy on the cultivation of
GE crops has created an environment in which the aims of
the Lisbon Strategy can never be achieved. The policy sets
a framework for coexistence measures ensuring sufficient
segregation between GE and conventional crops, thus
offering choice to farmers and consumers [3,4], but also
encourages the haphazard implementation of these measures without coordination or a rational scientific basis,
including plans to allow member states and their regions
an unconditional opt-out. This has imposed a de facto
moratorium on GE maize (Zea mays) and soybean (Glycine
max) crops in Europe, even though these same GE products
are imported because there is insufficient capacity to grow
these crops using conventional agricultural practices [5].
The second paradox is the CAP, which aims to ensure a
stable supply of high-quality food for the EU population at
fair prices while providing farmers with a reasonable standard of living and preserving rural heritage [6]. However,
most of the subsidies available under the CAP are used to
benefit large producers rather than family farms
(http://www.attac-netzwerk.de/fileadmin/user_upload/
AGs/Agrarnetz/EU-Agrarpolitik/marita_eusubsidies.pdf),
and the dumping of CAP-subsidized EU products disrupts
agriculture in developing countries (http://www.cedia.eu/en/
policy/2011/swiss_paper_cap_policy_2011.pdf). The third
paradox is the contrast between policy aims and outcomes.
Trends in Plant Science xx (2013) 1–13
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TRENDS in Plant Science
Figure 1. The world’s top five (A) exporters and (B) importers of agricultural products (reproduced from http://ec.europa.eu/agriculture/trade-analysis/map/05-2012_en.pdf).
(A) EU exports fell in 2009 but increased in 2010 and 2011 to record levels. (B) The EU is currently the largest importer in the world, although the USA and China have
increased imports since 2009.
For example, the EU has banned many pesticides, but
approves the import of food products treated with banned
chemicals (http://europa.eu/legislation_summaries/food_
safety/plant_health_checks/l21289_en.htm; http://eur-lex.
europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1976:
340:0026:0031:EN:PDF).
This review focuses on the role of GE agriculture, how its
deployment in Europe is necessary to achieve the stated
goals of EU agricultural policy, and how continued resistance is placing short-term political and economic interests
above the long-term goals of environmentally sustainable
agriculture, food safety, and human health (Table 1). The
2
suppression of GE agriculture in the EU is widely recognized
as ideological rather than scientific, driven to a large extent
by the organic food industry in an effort to protect organic
food premiums at the expense of overall competitiveness [3].
This policy is actively working against the EU’s own goals,
driving research, development and innovation abroad, and
granting commercial and economic benefits to other countries that then sell the products back to EU member states
[5]. The EU is thus becoming increasingly uncompetitive
and isolated in the international markets, which thrive on
innovation and technological development in agriculture
[7,8].
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Trends in Plant Science xxx xxxx, Vol. xxx, No. x
Table 1. Paradoxes among agricultural and health policies of the EU
Policy
Knowledge-based economy
KBBE
Agricultural policy
CAP
Trade policy
Treaty on the Functioning
of the EU Article 207 EC
Coexistence measures
Recommendation
2003/556/EC
Recommendation
2010/C 200/01
Intention
Reality
Consequences
Solution
To promote European
competitiveness based
on excellent science and
technology using
industry as a base to
deliver innovations.
The development of
innovations in GE
agriculture is blocked,
SMEs are failing and
major industry is moving
overseas.
EU agriculture will not
benefit from innovations and
its competitiveness will be
reduced.
Promote high-quality
agricultural biotechnology,
in both the public and private
sectors by streamlining the
regulatory pathway for GE
crops.
Increase agricultural
productivity and ensure a
good standard of living
for the agricultural
community, stabilize
markets, and ensure fair
prices for consumers.
Promotes the
overproduction of
noncompetitive
commodities, inequality
in the distribution of
subsidies, and the
artificial competitiveness
of EU produce. Isolates
the EU from world
market fluctuations.
A substantial portion of the
EU budget is wasted. Large
producers gain subsidies at
the expense of small
farmers. Products are
dumped on developing
country markets damaging
local infrastructure. The
adoption of competitive
technologies such as GE
crops is obstructed.
Increase competitiveness by
adopting agricultural
innovations such as GE
crops. Combine a reduction
in subsidies with policies
that prevent dumping.
Reduce the overproduction
of crops.
Balance agricultural
import and export to
meet the demands of
home and export markets
in the most economically
beneficial manner.
EU imports animal feed
(mainly soybean and
maize) because it cannot
meet home demand.
More than 80% comes
from GE producers, with
39 GE crops authorized
for import but only 2 (1
food crop) for cultivation.
Member states do not
allow their own farmers
to grow GE crops even if
they are identical to
imported varieties.
Imports must meet EU
thresholds for
adventitious presence.
EU farmers cannot use new
technologies such as GE to
increase competitiveness.
Imported foods are
impounded if they fail EU
thresholds, creating trade
barriers, economic damage
to importers and exporters,
and the perception of the EU
as an economic risk for
exporters. Decline in overall
trade with the rest of the
world.
Rationalize and harmonize
EU policy on the cultivation
and import of GE crops.
Coexistence measures
should be transparent,
science-based, and
proportionate and should
embrace cross-border
cooperation, equal
stakeholder involvement,
and coherent liability
rules to provide farmers
with freedom of choice.
Coexistence measures
are purely an economic
issue. They are neither
proportionate nor
science-based and
discriminate against
farmers seeking the
choices the measures are
meant to promote. They
place farmers at risk of
litigation and effectively
ban GE agriculture in
large areas of the EU.
The lack of EU-wide
regulations means that
member states can
impose arbitrary
minimum isolation
distances that have no
scientific basis and make
approval decisions for
political rather than
scientific reasons.
Suppression of GE
agriculture, which will
damage the EU economy
and global scientific
standing. Increases the
public’s negative perception
of GE crops. Reduces
freedom of choice.
Harmonization of
coexistence measures
throughout the EU with a
strict evidence-based
threshold for minimum
distances.
The creation of GE free zones
in Europe, pandering to
extremist views, and further
damage to the public’s
perception of GE agriculture.
Strict adoption of EU-wide
science-based rules for the
adoption of GE crops backed
up by legal sanctions against
countries that do not comply.
Autonomy for member
states to manage the
cultivation of GE crops
unilaterally, develop their
own coexistence
regulations, and overturn
EFSA recommendations
without presenting new
evidence, ostensibly to
prevent EU-wide bans
caused by a minority of
uncooperative member
states.
3
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Table 1 (Continued )
Policy
Environmental policy
Regulation (EC) 1698/2005
and Regulation (EC)
1257/1999
Regulation 396/2005/EC
Intention
Reality
Consequences
Solution
Improve the
competitiveness of the
agricultural and forestry
sector, improve the
environment and the
countryside, and
improve the quality of life
in rural areas by
encouraging
diversification of the rural
economy by increasing
agricultural subsidies.
Set maximum residue
levels (MRLs) for
pesticides used in the EU
to eliminate trade
barriers and increase
market transparency.
Subsidies, grants, and
export refunds do not
provide enough to keep
EU farmers competitive.
Market-driven agriculture
is reducing crop
diversity, promoting
deforestation, and
reducing long-term
sustainability.
Loss of competitiveness in
the rural farming sector and
rural economy generally.
Decentralize rural economy
measures and allow farmers
to use cost-saving
technologies that can
enhance productivity and
profitability in a more
sustained manner.
Allows the import of
foreign products treated
with pesticides banned in
the EU. Different MRLs
for home-grown and
imported products.
Farmers must reduce the use
of pesticides but must
compete with imports of
crops treated with the same
chemicals. Restriction to a
small number of essential
pesticides means that
resistance becomes more
likely. The MRLs set by the
EU are a trade barrier for
developing countries.
Increases the risk that pests
and pathogens will evolve
resistant populations against
the limited number of
permitted chemicals. More
effective chemicals cannot
be used thus overall
pesticide levels in the
environment increase.
Harmonize MRLs based on
scientific evidence and allow
the cultivation of GE crops
that are competitive without
the need for pesticides.
Promote
environmentally
sustainable practices by
banning many pesticides
and encouraging the use
of integrated pest
management and
nonchemical
alternatives.
Exception for ‘essential
pesticides’ that cannot be
replaced means that
farmers focus on a small
number of products but
overall use does not
change.
Ensure the protection of
public health and, where
appropriate, set
maximum levels for
certain contaminants.
Stringent levels for
mycotoxins compared
with the rest of the world.
EU policy on nutrition
Protect consumer health
while guaranteeing
smooth operation of the
single market by
ensuring that food
hygiene control
standards are
established and met,
reducing the risk of
contamination.
Directive 2001/83/EC
(also Regulation EC
726/2004 and EC 1394/2007)
Directive 2001/83/EC
requires individual
approvals for the
manufacture of health
products in the EU. The
other policy instruments
established the EMA and
set up rules to ensure the
free movement of
biotechnology-derived
drugs within the EU.
EU agriculture policy
blocks the development
of cost-effective
technologies that
increase the quality and
quantity of food grown in
Europe, and the
production of more
accessible
pharmaceuticals for the
EU and developing
countries.
The authorization and
marketing of novel
pharmaceutical products
from plants is regulated
jointly by the EMA and
the EFSA.
Regulation 1107/2009/EC
Health and safety policy
Regulation 165/2010/EEC
4
Generates a trade barrier
with countries unable to
meet EU limits. Benefits the
high-quality export market
for which the EU pays a
premium, whereas lower
quality commodities are
used for domestic markets in
developing countries.
Budget required for the
treatment of food-related
diseases and to meet the
costs of increased disabilityadjusted life years.
The development of novel
and inexpensive
pharmaceutical products is
hindered by regulatory
complexity, meaning that
both developed and
developing countries need
to pay more than necessary
for essential drugs.
Allow the use of pesticides
on a case-by-case basis
where minimum harm is
achieved. Allow the
cultivation of GE crops that
reduce pesticide usage.
Harmonize levels based on
scientific evidence. Allow the
cultivation of Bt crops that
reduce mycotoxin levels.
Allow the cultivation of crops
bred for increased nutrition
and pharmaceutical
production.
Unification of the regulations
so that there is a single
process for the approval of
medicines derived from
plants.
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The CAP no longer fits
The policy instruments encompassed by the CAP were
intended to provide farmers with a reasonable standard
of living while preserving rural heritage and ensuring a
stable supply of high-quality and fairly priced food within
the EU [6]. However, the objectives have changed over the
years, and now most of the subsidies go to large foodprocessing and trading companies along with the wealthiest farmers, protecting the larger industry players from
the economic impact of competition with imports [9]
(http://ec.europa.eu/agriculture/publi/app-briefs/01_en.
pdf), whereas small farms are largely ignored unless they
fall within the scope of rural development programs (http://
www.cedia.eu/en/policy/2011/swiss_paper_cap_policy_
2011.pdf) or they are linked to the organic farming industry
and become automatically eligible for payments because
of their perceived environmental benefit (http://www.
soilassociation.org/news/newsstory/articleid/2690/soilassociation-welcomes-cap-reform-announcements; http://
europa.eu/rapid/press-release_IP-11-1181_en.htm?locale=
en). Another major criticism is that direct payments and
export refunds promote the practice of dumping (i.e., exporting at prices below the cost of production), which allows
artificially competitive EU commodities to displace homegrown products in developing countries [10]. Similar criticism has been leveled at US Farm Bills [11,12].
Maintaining the CAP in its current state means that the
EU will continue to waste a large proportion of its budget
supporting uncompetitive producers and processers, while
poorer farmers remain in poverty and agriculture in developing countries is suppressed. GE agriculture would offer a
competitive advantage to food producers and processers
based on the adoption of new technology rather than
artificial subsidies. Some claim that reducing or abolishing
subsidies will not have the predicted positive impact on
prices and the welfare of small farmers [13]. Instead, they
propose a combination of reduced subsidies and policies
that place limits on export dumping, global commodity
overproduction in key crops, and the market power of
agribusiness conglomerates [14].
KBBE – support in principle, obstruction in practice
The Lisbon Strategy was launched in 2000 by the European Council to increase the productivity and competitiveness of the EU by aspiring to create ‘. . .the most dynamic
and competitive knowledge-based economy in the world. . .’
(http://www.europarl.europa.eu/summits/lis1_en.htm).
Knowledge is considered a valuable resource for economic
growth and social welfare, highlighting the importance of
investment in research and development [2]. Biotechnology and the life sciences were identified as essential components of this strategy with the establishment of the
KBBE, which accounts for s1.5–2 trillion of the EU gross
domestic product (Table 2) (http://www.bio-economy.net/
reports/files/KBBE_2020_BE_presidency.pdf).
A bioeconomy comprises all the industries that produce,
manage, or exploit biological resources. Because crops are
the major source of biomass used by humans, the EU has
recognized the potential of agricultural biotechnology as a
means to increase the yield and quality of economically
relevant crops [15]. But despite official acknowledgement
Trends in Plant Science xxx xxxx, Vol. xxx, No. x
Table 2. EU bioeconomy
Sector
Annual turnover
(billions of euro)
Employment
(thousands)
Food
Agriculture
Paper and pulp
Forestry and wood
Fisheries and
aquaculture
Biobased industries
Biochemicals
and plastics
Enzymes
Biofuels
Total
965
381
375
269
32
4400
12 000
1800
3000
500
EU
population
(%)
0.880
2.400
0.360
0.600
0.1 00
50 a
150 a
0.030 b
0.8 a
6c
2078
5a
150
22 005
0.001 b
0.030
4.400
a
Estimate 2009.
b
http://www.bio-economy.net/reports/files/KBBE_2020_BE_presidency.pdf.
c
Estimate based on the production of 2.2 million tons of bioethanol and 7.7 million
tons of biodiesel at average EU market price.
of the potential benefits, and generous funding of precompetitive research in this area, little has been done to
promote translational research and the commercialization
of agricultural technology so that the benefits are realized
at the farm and consumer levels. Indeed, the EU’s politicians and policymakers have actively obstructed the adoption of GE agriculture through the establishment of
complex and inconsistent regulations that strongly discourage farmers from considering the technology.
EU legislation for the approval of GE crops (Directive
2008/27/EC and Regulation EC 1829/2003) is the most
restrictive in the world. Regulatory compliance for a new
crop can cost up to s11 million and requires a dedicated
legal team working for many years [16]. For example, the
Amflora potato took 15 years to develop, 13 of which were
required for regulatory approval. Such onerous regulation
blocks the approval pathway to all but the most committed
and well-funded companies, preventing the realization of
innovation generated by public sector institutions and
small-to-medium enterprises (SMEs) unless they agree
to collaborate with major industry players [17,18].
Perhaps more importantly, the final decision for approval
is political rather than scientific. As part of the regulatory
process, a scientific opinion on safety must be sought from
the European Food Safety Authority (EFSA), the official and
expert scientific body charged with the task of safety evaluation in the EU. This opinion is based on the views of expert
panels that consider the available scientific evidence. However, the opinions of the EFSA are routinely ignored by
many member states and the EU has recently approved a
plan to allow member states an opt-out for the cultivation
of approved GE crops with no requirement for scientific
justification or evidence of risk (http://www.europabio.
org/sites/default/files/europabio_-_ernst_young_report___
what_europe_has_to_offer_biotechnology_companies.pdf;
http://www.europarl.europa.eu/news/en/headlines/content/
20110627FCS22686/8/html/GMOs-Parliament-backsnational-right-to-cultivation-bans). Although the ostensible
reason for the proposal is to allow member states to adopt
GE agriculture on an individual basis rather than relying
on voting in the European Parliament, the European
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Commission, and ultimately the Council of Ministers, the
opt-out may only serve to legalize the formerly illegal
(although widely practiced) strategy of declaring GE-free
zones within the EU, thus damaging not only the EU
economy but also its global scientific standing and opposing the basis of the Common Market [5].
The lack of GE agriculture in the EU is an overall
symptom of the promising but poorly executed Lisbon
Strategy. By failing to uphold the rights of farmers to
adopt GE crops, the EU is moving rapidly away from
the KBBE model, actively discouraging innovation and
investment in the sector, stifling the growth of SMEs,
driving research and development abroad, and therefore
handing the EU’s competitive advantage to the industry in
North and South America and Asia (http://www.basf.com/
group/corporate/en/function/conversions:/publish/content/
news-and-media-relations/news-releases/downloads/2012/
P109e-PlantBiotechnology.pdf).
Farmers – choice in principle but not in practice
EU policy officially supports the coexistence of GE and
conventional agriculture, and lays down coexistence regulations by allowing member states to establish minimum
distances between fields of GE and conventional crops to
prevent admixture. Coexistence refers to the ability of
farmers to make a practical choice among conventional,
organic and GE crops, in compliance with legal obligations
for labeling and/or purity standards as defined in European Commission legislation. The European Commission
has published detailed and pragmatic recommendations
for the development of coexistence regulations for implementation at national or regional levels, based on a tolerance threshold for adventitious presence above which
a conventional crop must be labeled as containing GE
(http://ec.europa.eu/agriculture/publi/reports/
material
coexistence2/index_en.htm). Despite the absence of any
science-based public health or environmental safety justifications, the regulations were developed in response to
lobbying by self-regulating organic industry groups which
claimed that adventitious presence could reduce the value
of a conventional or organic crop, particularly the latter,
which is often sold at a premium. This implicitly acknowledges that coexistence measures are concerned with the
economic impact and not the health or environmental
safety of the product, given that no GE crops can be grown
without a positive safety evaluation from the EFSA [19,20]
(http://www.gmcc13.org/files/proceedings_gmcc05.pdf).
The adventitious presence thresholds in the EU are the
strictest in the world. There is a two-tier tolerance policy
(EC 1830/2003) with a 0.9% adventitious presence limit
applied to approved products and zero tolerance applied to
unapproved products, replacing the temporary 0.5% second-tier limit previously approved by the EFSA. There are
clear scientific principles that can be used to establish
acceptable minimum distances between GE and conventional crops and other mitigation strategies to achieve
these thresholds, and these principles are explained in
Recommendations 2003/556/EC and 2010/C 200/01 to allow the development of national coexistence strategies and
best practices. The major changes in Recommendation
2010/C 200/01 provide individual member states with
6
Trends in Plant Science xxx xxxx, Vol. xxx, No. x
greater flexibility and responsibility for their own coexistence policies, aiming to speed up pending authorizations
by removing the ability of those member states to veto
approvals throughout the EU. However, the practical effect
of these recommendations has been to allow member states
to impose arbitrarily large minimum distances between
conventional and GE crops so that GE agriculture is effectively prevented unless farmers agree to surround their
crops with large areas of uncultivated land or risk litigation from surrounding farms [5,21]. As a consequence,
only 100 000 ha of GE crops was grown in the EU in 2012
(http://www.isaaa.org/resources/publications/briefs/43/).
In Luxembourg, for example, it is necessary to leave 800 m
between GE and non-GE maize plots and 3 km between GE
and non-GE rapeseed (Brassica napus) plots. Similarly in
Latvia, it is necessary to leave 4 km between GE and nonGE rapeseed and 6 km if the non-GE rapeseed is organic
[4]. These national coexistence strategies do not comply
with most of the key coexistence principles established by
the European Commission, as summarized in Table 3.
Exaggerated coexistence measures are often justified in
the name of safety even though the principal reason is to
achieve established tolerance thresholds, but this nevertheless damages the perception of GE crops because most
consumers only note the nature of the regulations, not
the underlying justification. Coexistence measures are
therefore being used as a convenient and politically expedient proxy for EU policymakers to prohibit GE agriculture,
limiting the extent of GE agriculture in Europe to less than
115 000 ha in 2011 and approximately 100 000 ha in 2012
compared to 160 million ha in the rest of the world [3,4].
Most EU farmers are indirectly denied the choice of
growing GE crops and must therefore continue to use
unsustainable and uncompetitive farming practices, making them unwitting coconspirators to maintain the CAP. A
recent study showed that coexistence measures that actually ensured the coexistence of GE and non-GE crops
rather than preventing GE agriculture would alter the
attitude of farmers towards the adoption of GE technology
[22]. GE crops would reduce production costs by reducing
pesticide use, labor, and fuel consumption, resulting in
significant economic benefits (http://ec.europa.eu/food/
plant/gmo/reports_studies/docs/economic_performance_
report_en.pdf). However, the ability of member states to
impose their own rules means that farmers choosing to
adopt GE crops in nonsupportive member states lose any
economic advantages the technology might bring through
the costs of compliance, negotiations with surrounding
farms, and insurance to cover litigation in the event of
admixture [23]. The obligations placed on farmers growing
conventional or organic crops are much less restrictive
than those growing GE crops [23–25].
Safe to eat, but only if imported
As discussed above, food derived from approved GE crops
has been deemed safe for human consumption by the
EFSA. Approval must also be granted by the equivalent
body in the USA, which comprises experts from the US
Department of Agriculture (USDA) and the Food and
Drugs Administration (FDA). Notably, even in the highly
litigious USA, there have been no lawsuits, no product
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Table 3. Paradoxes among coexistence measures of the EUa
Principle
Transparency
Cross-border cooperation
Stakeholder involvement
Based on scientific evidence
Proportionality
Liability
Intention
National strategies and best practices for coexistence
should be developed in a transparent manner.
Member states should ensure cross-border cooperation
with neighboring countries to guarantee the effective
functioning of coexistence measures in border areas.
National strategies and best practices for coexistence
should be developed in cooperation with all relevant
stakeholders.
Management measures for coexistence should reflect the
best available scientific evidence on the probability and
sources of admixture between GE and non-GE crops.
Measures to avoid the unintended presence of genetically
modified organisms (GMOs) in other crops and vice versa
should be proportionate to the intended objective
(protection of the particular needs of conventional, organic,
and GE farmers).
The policy instruments adopted may have an impact on
national liability rules in the event of economic damage
resulting from admixture.
Consequence
Coexistence requirements are confusing and those
implementing them are unaccountable [3,4].
There is no cooperation because member states act
independently and national governments are
responsible for coexistence policies. Each member
state establishes a legislative framework on a cropby-crop basis [3,4].
GE farmers are sidelined. Farmers who choose to
grow GE crops have to invest extra money to comply
with the excessive coexistence measures [21,23].
The thresholds for adventitious presence are far
stricter than for conventional crops and the isolation
distances enforced to achieve such thresholds are
arbitrary, excessive, and are politically motivated
rather than reflecting scientific reality [3].
Measures are neither regionally nor economically
proportionate [23]. Proportionality is still linked to
economic loss even if not necessarily to the labeling
thresholds [3].
Strict liability regulations mean that GE farmers are
always responsible for any admixture and risk fines
or litigation from surrounding farms [3,4,21,23].
a
http://ec.europa.eu/agriculture/publi/reports/coexistence2/index_en.htm.
recalls, no reported ill effects, and no other evidence of risk
from a GE product intended for human consumption since
the technology was first deployed commercially in 1996.
The perceived risks of GE food and feed to human health
persist in the EU despite all the contrary evidence from the
regulators and the lack of harm in countries that have
embraced the technology. Further evidence comes paradoxically from the population of the EU itself, which
regularly consumes GE food imported from other countries
because the restrictions that apply to home-grown GE
foods do not apply to imports. Indeed, the EU is largely
dependent on GE products from abroad [25]. Approximately
80% of animal feed consumed in the EU is imported, of which
more than half is GE produce imported from countries such
as Brazil, the USA, and Argentina, which are the largest
exporters of GE products [25] (http://www.europabio.org/
sites/default/files/position/pocket_guide_gmcrops_policy.
pdf). The EU is dependent on soybean meal from South
America and dried distillers’ grains of maize from the USA
(Figure 2) [26]. In 2009, the 12.9 million tons of maize
imported into the EU included 69% (8.9 million tons) and
17% (2.2 million tons) from Brazil and the USA, respectively
[25].
EU policy on GE food imports is less restrictive than the
regulations covering GE agriculture in the EU owing to its
dependence on imports to maintain the livestock industry.
This explains the big difference between the numbers of
crops approved for import and cultivation (Figure 3; http://
www.europabio.org/sites/default/files/report/approvals_
of_gmos_in_eu_europabio_report.pdf). A total of 39 different GE crops were approved for import in 2011/2012: 24
varieties of maize, 7 of cotton (Gossypium spp.), 3 of
rapeseed, 3 of soybean, and 1 variety of sugar beet (Beta
vulgaris) (http://www.gmo-compass.org/). In contrast, only
two products have been approved for cultivation, the pestresistant maize variety MON810 and the Amflora potato
variety, which is for industrial starch production rather
than food use (http://gain.fas.usda.gov/Recent%20GAIN%
20Publications/Biotechnology%20-%20GE%20Plants%
20and%20Animals_Paris_EU-27_7-23-2010.pdf). Even so,
cultivation of the Amflora potato was prohibited in Germany
in September 2010 due to intermixture with another GE
potato variety that has not yet been approved, during its
cultivation in Sweden (http://www.gmo-compass.org/eng/
news/536.iamflorai_potato_intermixing_sweden_ban_
germany.html). These barriers eventually persuaded the
developer BASF to move production abroad because
‘. . .there is still a lack of acceptance for this technology in
many parts of Europe. . .’ (http://www.basf.com/group/corporate/en/function/conversions:/publish/content/news-andmedia-relations/news-releases/downloads/2012/P109ePlantBiotechnology.pdf).
The member state opt-out discussed above only applies
to cultivated GE crops because EU member states are not
legally permitted to block the marketing of approved
imported GE products. This means that EU markets are
flooded with imported GE products that could just as easily
be grown in the EU, and that member states such as
Austria, Belgium, or Luxembourg with some of the most
hostile policies towards GE crops need these imported
products the most. The absurdity of this position is that
a ban on cultivation often means that GE soybean, maize,
or cotton is imported instead, which undermines claims
that GE crops should not be grown because they are unsafe
[5] (http://ec.europa.eu/research/biosociety/pdf/a_decade_
of_eu-funded_gmo_research.pdf).
Although less stringently regulated than cultivation,
the import of GE products is nevertheless still heavily
controlled, causing logistic and economic problems for
exporters and EU importers alike, reducing the flow of
commodities and threatening the stability of the livestock
industry. The import approval process differs between
7
TRPLSC-1050; No. of Pages 13
Review
Trends in Plant Science xxx xxxx, Vol. xxx, No. x
(A)
Total import:
€ 98 billion
6- Crude palm oil
1.9%
7- Tobacco
1.9%
8- Wine of fresh
grapes
1.7%
9- Raw cane
sugar
1.6%
5- Bananas
2.9%
Selected
products:
42% share
10- Maize
1.5%
11- Rape or colza seeds
1.3%
12- Food
preparaons, n.e.s.
1.2%
4- Cocoa beans
3.7%
13- Fresh grapes
1%
14- Poultry meat
1%
15- Bovine meat,
boneless
<1%
3- Soybeans
4.7%
2- Soybean meal
6.2%
1- Coffee
8.4%
Source: EUROSTAT-COMEXT
(B)
Total export:
€ 105 billion
10- Spirits
2.1%
11- Food prep
for infant use
1.7%
9- Cigarees
2.3%
Selected
products:
40% share
12- Prep for
animal feeding
1.6%
13- Solid milk
and cream
1.8%
14- Sparkling Wine
1.6%
8- Cheese
2.3%
15- Chocolate
1.5%
7- Beer
2.2%
1- Wine
6.1%
6- Frozen pigmeat
2.9%
5- Wheat
3.5%
4- Odoriferous
subst
3.7%
2- Food prep
3.9%
3- Whiskies
3.8%
Source: EUROSTAT-COMEXT
TRENDS in Plant Science
8
TRPLSC-1050; No. of Pages 13
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Trends in Plant Science xxx xxxx, Vol. xxx, No. x
100
89 products for
food/feed/import
90 products for
food/feed/import
90
Number of products
80
66 products
for
culvaon
70
60
50
40
39 products for
food/feed/import
28 products for
food/feed/import
30
20
10
2 products
for
culvaon
0
European Union
United States
Key:
Culvaon
Brazil
Canada
Import
TRENDS in Plant Science
Figure 3. Number of approved genetically engineered (GE) products in the EU, USA, Brazil, and Canada (http://www.europabio.org/sites/default/files/report/
approvals_of_gmos_in_eu_europabio_report.pdf). The EU has the lowest number of approved products for cultivation, MON810 and the Amflora potato. However, 39
products are approved for import, compared to the USA and Brazil, where 1 approval covers both import and cultivation.
countries, which causes delays and asynchronous authorizations in different parts of the world [26]. The zero
tolerance for the adventitious presence of GE products
that have not yet been approved for import into the EU
results in shipments containing traces of GE material that
are approved by the exporter being rejected at the point of
import, with significant economic consequences for both
the EU and the supplier, particularly if the supplier is a
developing country [27]. Europe is increasingly being perceived as a risky export market, resulting in preferential
trading between other countries, and EU importers bearing high prices and insurance premiums to offset risks
undertaken by the supplier [25] (http://ftp.jrc.es/EURdoc/
report_GMOpipeline_online_preprint.pdf). The situation
described above may worsen with the increasing adoption
of GE agriculture as a mainstream technology outside the
EU, leading to deficits initially in the demand and supply
chain for soybean meal and then in the feed industry more
generally, with a knock-on effect on the livestock, poultry,
and dairy industries and economic decline throughout the
EU [8,27].
Sustainability – promoted in principle but discouraged
in practice
Agricultural sustainability is a key program within the
CAP and has a strong impact on market forces and the food
supply chain (http://ec.europa.eu/agriculture/publi/appbriefs/01_en.pdf). Subsidies based on land use are provided
to encourage environmentally responsible cultivation
methods and reduce the use of chemicals and pesticides
(http://aei.pitt.edu/559/1/1_Bandarra.pdf). However, the
subsidies have instead resulted in the intensification of
agriculture and a dramatic increase in the use of fertilizers
and pesticides, thus increasing the rate of environmental
damage (http://www.wwf.org.uk/filelibrary/pdf/ag_in_the_
eu.pdf). The restriction of pesticide use has encouraged
farmers to rely on a small number of permitted chemicals,
risking the emergence of resistant pest populations and
making agricultural sustainability difficult to achieve
[28].
Integrated approaches can help to achieve sustainability, and biotechnology can play a crucial role in this process
as seen in other parts of the world [29]. For example, the
cultivation of insect-resistant GE crops has reduced the use
of pesticides in India and China, improving the environment and the health of farmers [30]. GE papaya (Carica
papaya) that is resistant to Papaya ring spot virus has
improved disease management in Hawaii, resulting in a
sustainable supply of papaya fruits for the domestic population [31]. Furthermore, the cultivation of herbicide-tolerant crops in the Western Hemisphere has promoted
reduced/zero-tillage farming to reduce soil erosion and
water contamination caused by agriculture [32].
Insect-resistant maize in Europe provides efficient pest
control without pesticides, also limiting the impact of
agriculture on nontarget organisms while increasing yields
and the net economic benefits of farming. This has been
realized in countries such as Spain, where GE crops are
still encouraged, whereas other parts of the EU see no
benefit because of the costs of compliance with national
Figure 2. The main agricultural (A) imports and (B) exports in the EU (reproduced from http://ec.europa.eu/agriculture/trade-analysis/map/05-2012_en.pdf) (A) Coffee is the
main agricultural product imported into the EU, followed by soybean meal and soybeans, which represent 11% of EU agricultural products, then maize. After these, the next
agricultural product that is imported to Europe is maize, which is tenth in the list. (B) Approximately 64% of EU agricultural exports are finished products, whereas
commodities and intermediate products represent 8% and 19%, respectively (average 2009–2011). The top EU export is wine (s6.1 billion) followed by prepared foods
(s4 billion) and whiskies (s3.9 billion).
9
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regulations [33]. Mycotoxin levels in GE maize are much
lower than those in conventional maize, therefore reducing
the risk of acute toxicity effects and long-term health issues
[34]. The deployment of Bt maize has reduced pesticide use
in Spain and has led to a significant reduction in mycotoxin
levels, compared to conventional maize [35]. Growing Bt
maize throughout the EU could achieve annual savings of
up to 700 tons of pesticide active ingredient, adding to the
current 443 000 tons saved globally by the cultivation of
pest-resistant maize and cotton [36] (http://ec.europa.eu/
food/food/biotechnology/reports_studies/docs/Europabio_
contribution_II_en.pdf). Between 1996 and 2010, GE agriculture has reduced fuel use and increased carbon sequestration, thus reducing the carbon footprint of agriculture
by 146 million tons [36].
Despite the economic and environmental benefits
demonstrated in other regions, EU policies continue to
block the adoption of approved GE crops [18,37,38]. Developing countries that formerly embraced GE agriculture as
a means to improve the health and welfare of subsistence
farmers are being discouraged because of the hurdles they
encounter when exporting their produce to the EU. The
reluctance of the EU to accept GE commodities has diminished the enthusiasm of developing countries to approve
GE crops. This is the case in Egypt, where the likelihood of
a ban on the import of GE potato into the EU has delayed
the approval of this crop. Similarly in Thailand, the government has refused to approve the cultivation of GE crops
because they fear losing export markets in Europe (http://
agbioforum.org/v7n12/v7n12a12-kent.pdf).
Pesticides – banned but not forgotten
European Commission regulations EC/396/2005 and 1107/
2009/EEC were introduced to harmonize the maximum
residue levels (MRLs) for pesticides in food and feed and to
reduce pesticide use in agriculture, particularly by prohibiting the use of certain chemicals deemed to be hazardous
[39]. A special essential-use category was created to extend
the use of pesticides that could not be replaced, giving
manufacturers 5 years to make the product safe. However,
if alternative products are still not available after that
period then farmers will be able to continue using them for
another 5 years (http://www.pan-europe.info/Resources/
Links/Banned_in_the_EU.pdf; 1107/2009/EEC). The regulations create the impression that the EU is making efforts
to reduce pesticide use in agriculture, but in reality they
favor the use of a small number of chemicals thus greatly
enhancing the risk that resistant pest populations will
emerge. Meanwhile, imported food treated with banned
products is still approved, thus EU citizens are still exposed to banned pesticide residues but through the import
chain rather than those used and regulated in the EU. The
EU MRLs for pesticides are exceeded in 6.9% of imported
agricultural products but in only 1.5% of home-grown
products (http://www.efsa.europa.eu/en/press-/news/
111108.htm) because Regulation 396/2005 allows pesticide
thresholds to be set at different levels for imported products, including the threshold for substances that are no
longer authorized in the EU (http://europa.eu/legislation_
summaries/food_safety/plant_health_checks/l21289_
en.htm).
10
Trends in Plant Science xxx xxxx, Vol. xxx, No. x
EU pesticide-use policies are intended to promote environmentally sustainable agriculture (i.e., farmers should
protect their crops without using chemicals if possible or
combine them with measures that reduce the amounts
required). The net result is that EU farmers lose the ability
to protect their crops effectively in many cases, and the
lower yields need to be compensated by the import of food
from outside the EU even though it has been treated with
products that are banned in the EU. Because the MRLs for
crops grown in EU countries are lower than those for
imported crops, EU farmers are prevented from competing
with farmers outside the EU because the regulations favor
the market for imported foods.
Directive 2009/128/EC establishes a framework for community action to achieve the sustainable use of pesticides:
‘Member States shall take all necessary measures to promote low pesticide-input pest management, giving wherever possible priority to non-chemical methods’. In
practice, however, this legislation does little to promote
nonchemical methods. For example, Diabrotica virgifera
virgifera is a maize pest that was accidentally introduced
into Europe from the USA in the early 1990s, and it now
causes substantial yield losses in Central Europe. GE crops
provide effective protection against the pest in the USA
and additional pesticides are not required. Directive 2009/
128/EC advocates the use of such crops because they
facilitate nonchemical control methods, and an expert
study commissioned by the EU states that ‘. . .the main
benefits of transgenic varieties are an increased protection
of the root system, a decrease of volumes of insecticides
being used by farmers in soil treatments, and an easy
management for the farmers. . .’. Even so, EU farmers in
affected areas and neighboring regions are obliged to use
pesticides because the only GE maize variety authorized
for cultivation in the EU is MON810, which is not resistant
to D. virgifera (http://ec.europa.eu/food/plant/organisms/
emergency/final_report_Diabrotica_study.pdf). There is a
similar contradiction in Regulation 1107/2009. Insect pheromones and other semiochemicals are widely used in
European orchards and vineyards to control insect pests
by disrupting mating. However, the regulations for marketing plant protection products apply to all substances
regardless of origin and properties, which means that the
same lengthy and expensive approval process must be
followed for a natural and ubiquitous volatile chemical
emitted by female insects to attract males as that required for a highly toxic synthetic pesticide [40]. Dozens
of active natural products that are potentially useful in
agriculture and that are not harmful to humans or the
environment cannot be marketed in the EU due to this
legislation.
The MON810 maize variety has been grown in Spain for
more than 14 years. During that time there have been no
reports of health issues for consumers, resistant pest populations, or of impacts on nontarget organisms [34,41]. However, there has been a significant reduction in pesticide use
for borer control as well as economic benefits for farmers
(http://www.europabio.org/sites/default/files/position/europabio_socioeconomics_may_2011.pdf). Many other GE
varieties with favorable EFSA opinions are mired in the
regulatory process, awaiting clearance for commercial
TRPLSC-1050; No. of Pages 13
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cultivation, while known harmful pesticides continue to be
used.
Mycotoxin safety levels – moving the goalposts
Mycotoxins are secondary metabolites produced by certain
filamentous fungi that infect crops and stored food such as
cereals, nuts, spices, dried fruits, apple juice, and coffee [42].
If consumed, these compounds can be acutely toxic to
humans (mycotoxicosis) and cause long-term carcinogenic
effects [43]. The tolerance levels set for mycotoxins are
highly controversial because they imply a compromise between human health and economic factors (http://agecon.
ucdavis.edu/people/faculty/roberta-cook/docs/links/LCfoodsafettrade03.pdf). In 1997, the EU harmonized the acceptable level of aflatoxin contamination in groundnuts (Arachis
hypogaea) at 10 ppb for groundnuts intended for further
processing and at 4 ppb for cereals intended for direct
human consumption. This caused a sudden reduction in
imports into some member states and the levels were
strongly criticized by many members of the World Trade
Organization (WTO) because the measures would create a
trade barrier for countries economically dependent on
exports to the EU. In response, the thresholds were increased in 1998 to 15 ppb in groundnuts intended for further
processing (8 ppb for aflatoxin B1, which is the most toxic
mycotoxin) and 4 ppb for foods intended for direct consumption (2 ppb for aflatoxin B1) [44].
The policy instrument used to set the maximum levels
for aflatoxins in food is Regulation 165/2010/EC, which has
doubled the tolerance threshold to 8 ppb but provides an
exemption in that levels are expected to be ‘. . .as low as can
reasonably be achieved. . .’ This was justified on the advice
of the Scientific Panel on Contaminants in the Food Chain
(CONTAM), which stated that exceeding the maximum
levels occasionally would have a low overall impact on
health. Therefore, standards have been lowered in developed countries that have the technology to detect and thus
avoid mycotoxins in food in a cost-effective manner, but
have remained stringent for developing countries without
these capabilities, blocking their export markets [45]. Furthermore, attempts to meet these demands mean that
developing countries export their highest quality food,
leaving the poverty stricken domestic population to consume mycotoxin-contaminated food that cannot be
exported [46]. The restriction of the market in this manner
also results in the EU paying more for higher quality foods
[47].
However, GE agriculture could provide a solution to this
challenge. For example, Bt maize is resistant to insect
pests that cause damage and allow penetration by mycotoxin-producing fungi [48]. MON 810 is the only GE maize
variety approved in the EU, but under the proposals for a
member state opt-out it could soon disappear from much of
the continent. However, to meet its stringent requirements
for mycotoxin-free maize, the EU imports the MON 810 GE
maize variety as well as other more advanced Bt varieties
from other countries [5].
Road to nutrition
One of the major global health challenges is malnutrition.
Approximately half the world’s population (including 5% of
Trends in Plant Science xxx xxxx, Vol. xxx, No. x
the EU population) suffers from malnutrition, yet the
biofortification of crops could provide a method to address
this problem and could potentially save lives [49–51]. EU
policies on food and nutrition are described in the European Commission White Paper on Food Safety (2000) (http://
ec.europa.eu/dgs/health_consumer/library/pub/pub06_en.
pdf). The fortification of processed food and agronomic
biofortification using nutrient-rich fertilizers has overcome
the lower endogenous levels of some nutrients in the UK
and Finland [52,53]. However, the biofortification of crops
with essential minerals and vitamins by genetic engineering can yield nutritious foods more rapidly and more
sustainably by equipping plants with the means to synthesize, absorb, and accumulate nutrients at source [54–57].
The development of Golden Rice, a variety of rice (Oryza
sativa) enriched with b-carotene [58], multivitamin corn
enriched with ascorbate, b-carotene, and folate [59], and
folate-biofortified rice [60] are key examples of successful
biofortification achieved through EU public sector research [50]. However, because of the regulatory burden
on GE crops, no nutritionally enhanced varieties are likely
to be grown for consumption in the EU [5,61] or in developing countries that are economically dependent on trade
and/or aid from the EU (http://www.adelaide.edu.au/cies/
publications/present/CIES_DP1012.pdf).
DNA sequencing has revealed that biotechnology is less
disruptive to the genome than conventional plant breeding
because the transgene insertions are localized [62]. Transgenic plants with novel traits also resemble the parental
variety more closely than those generated by introgression
[63]. GE biosafety research in Europe over the past 25
years has cost more than s300 million and can be summarized in one sentence: GE is no more dangerous than crop
modification by any other method. This has been confirmed
by a recent EU study that revealed no greater risk from the
consumption of GE maize than any conventional variety
[64] (ftp://ftp.cordis.europa.eu/pub/fp7/kbbe/docs/a-decadeof-eu-funded-gmo-research_en.pdf).
Even with this extensive research to support the safety
of GE crops backed up by 15 years of consumer safety in the
USA and elsewhere [65], GE varieties must undergo compositional, allergenicity and toxicity testing, molecular
characterization, and environmental impact assessments
from which conventionally bred varieties are exempt even
if they are identical in every way to the GE variety [66].
Effectively, EU regulations do not focus on the product,
only on the process [67].
Medical innovation – giving with one hand, taking with
the other
In addition to malnutrition, several key diseases prevalent
in developing countries are major global health challenges,
including HIV/AIDS, tuberculosis, malaria, and rabies.
Many people die from these diseases because of the lack
of drugs, often reflecting poverty and limited access to
medical facilities rather than the availability of those
facilities per se [68]. The EU has invested in research
projects focusing on the development of inexpensive diagnostics, drugs, and vaccines, and the platforms to produce
them in developing countries (http://ec.europa.eu/research/
health/infectious-diseases/antimicrobial-drug-resistance/
11
TRPLSC-1050; No. of Pages 13
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pdf/infectious-diseases-leaflet09_en.pdf; http://www.
pharma-planta.net/).
GE crops provide an alternative platform to chemical
synthesis for the production of pharmaceutical molecules
because they can produce large amounts of biomass that
can be scaled up and down as required to meet demand
[69–72]. Diverse pharmaceutical products have been produced in plants, including vaccines, antibodies, and
enzymes [69,73]. Innovative plant-derived pharmaceuticals include edible vaccines [74], microbicides to prevent
the transmission of HIV [75], and recombinant versions of
insulin and human growth hormone [76]. The slow adoption of pharmaceuticals produced in whole plants in the
field reflects the slow development of the regulatory process, which involves not only the European Medicines
Agency (EMA) but also the EFSA, which has a mandate
to consider non-food plants as well as those used for food [77].
The cultivation of GE plants for pharmaceutical use needs to
meet the requirements stated in Directive 2008/27/EC,
which regulates ‘the release’ of GE plants into the field,
and Regulation 1829/2003/EC, which sets out rules governing food and feed products. Finally, plant-derived pharmaceuticals must meet the specific guideline established by the
EMA to regulate the production process to determine the
final safety of the pharmaceutical product (http://www.
ema.europa.eu/docs/en_GB/document_library/Scientific_
guideline/2009/09/WC500003154.pdf).
Similar to the other benefits of GE agriculture, pharmaceutical research is being hindered by the huge investment required at the precompetitive stage so that novel
products can negotiate the regulatory pathway beyond the
proof-of-principle stage. Drugs that can be produced inexpensively in plants are currently produced in cultivated
mammalian cells at great expense [72], beyond the reach of
developing countries. The luxury of onerous regulation in
the EU is costing lives in the developing world.
Concluding remarks and recommendations
The EU has enacted a series of strategies whose stated
aim is to develop the most competitive knowledge-based
bioeconomy in the world. So far this has failed. One reason
for the disappointing performance is the paradoxical nature of the agricultural policies described in this review,
many of which are contradictory, anticompetitive, and
actively promote the practices they claim to discourage.
In many cases, this is because policies are based on
political expediency and short-term economic goals rather
than rational scientific evidence and long-term economic
models.
To reverse this situation, the EU needs to consider rational principles as the basis for policy development, removing
inconsistencies surrounding the cultivation and import of
GE crops, and the acceptable levels of pesticide residues and
mycotoxins. This would make the EU agricultural industry
more competitive and international trade would be harmonized. Most importantly, by rationalizing its policy framework, innovative new crops, drugs, and novel and efficient
production methods would come to market more rapidly and
the EU would become a leading influence in the use of
technology to save lives. Following the current path, the
EU faces being left behind technologically, economically,
12
Trends in Plant Science xxx xxxx, Vol. xxx, No. x
and in terms of its humanitarian policies, to the detriment of
the EU population and the rest of the world.
Acknowledgments
Research at the University of Lleida is supported by the Ministerio de
Ciencia e Innovación (MICINN), Spain (BFU2007-61413; BIO201123324; BIO02011-22525; PIM2010PKB-00746; AGL2011-23996); the
European Union Framework 7 Program SmartCell Integrated Project
222716; the European Union Framework 7 European Research Council
IDEAS Advanced Grant (to P.C.); Program-BIOFORCE; COST Action
FA0804: Molecular farming: plants as a production platform for high
value proteins; Centre CONSOLIDER on Agrigenomics funded by
MICINN, Spain and RecerCaixa. We thank Gustavo Slafer and Roxana
Savin for useful comments and suggestions.
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